Proposed Consent Agreement In the Matter of Service Corporation International and Stewart Enterprises, Inc.; File No. 131-0163 #00014

Proposed Consent Agreement In the Matter of Service Corporation International and Stewart Enterprises, Inc.; File No. 131-0163 #00014

January 10, 2014

Submission Number:

00014

Commenter:

Lloyd Wolf

State:

Virginia

Initiative Name:

Proposed Consent Agreement In the Matter of Service Corporation International and Stewart Enterprises, Inc.; File No. 131-0163

Dear People, The FTC was correct in recognizing that the merger of SCI and Stewart would harm competition in the Jewish funeral home market in the DC/MD area. However, the proposed remedy of requiring the divestiture of Edward Sagel Funeral Direction is wholly inadequate to protect competition in the market. Sagel is basically a storefront and lacks a chapel and adequate facilities to handle the deceased. It is wholly dependent on the SCI funeral home -- Danzansky -- for these services. Its market share has fallen from 25% to 11% in the last three years. If it is divested it is highly unlikely to remain an effective competitor in the market. Moreover, with the control of both Danzansky and Hines Rinaldi, SCI will still have the incentive and ability to deter the important competition provided by the Jewish Funeral Committee of Greater Washington contract. The current situation allowed my family to afford proper and affordable funeral arrangements for both my parents. I and my religious community were well-served by the current situation, which allows for competition and has resulted in an affordable arrangement with Hines-Rinaldi. As former chair of the Fabrangen, a Jewish religious congregation, I saw that this also worked best for many other members of our community. Please keep Hines-Rinaldi independent, as it best serves the public interest. I urge the Commission to revise the proposed consent decree and require the divestiture of Hines Rinaldi. Sincerely, Lloyd Wolf